State of Arizona, Appellee v. Sergio Arturo Rojo-Valenzuela, Appellant

Summary

The court held that an appellate court may determine the reliability of an inherently suggestive pretrial identification in the first instance when the trial-court record is sufficiently developed to permit an informed analysis. Although trial courts should make reliability findings before allowing identification evidence to reach the jury, reliability is a legal admissibility determination rather than a witness-credibility determination. The court affirmed the court of appeals and the defendant's convictions and sentences.